Housing Opportunities for Persons with AIDS HOPWA
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Housing Opportunities for Persons with AIDS HOPWA

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Program Description. A federally administrated grant program for state and local governments to develop a range of housing assistance and supportive services for low-income people living with HIV/AIDS and their familiesCreated through the National Affordable Housing Act of 1990Authorized by the
Housing Opportunities for Persons with AIDS HOPWA

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1. Introduction to HOPWA Housing Opportunities for Persons with AIDS (HOPWA)

2. Program Description A federally administrated grant program for state and local governments to develop a range of housing assistance and supportive services for low-income people living with HIV/AIDS and their families Created through the National Affordable Housing Act of 1990 Authorized by the AIDS Housing Opportunity Act of 1992 Administered by the Office of HIV/AIDS Housing (OHH) at HUD headquarters $3.5 Billion in HUD HOPWA appropriations 1992-2007

3. Allocation of HOPWA Funds

4. HOPWA Outcome Assisted households will: Have been enabled to establish or better maintain a stable living environment in housing that is decent, safe and sanitary Reduce risk of homelessness Improve access to health care and supportive services ? reduce disparities

5. Benefits to Clients A better housing situation ? more appropriate to needs Positive impact on health status through improved housing and access to care Reduce disparities in access to care

6. HOPWA Performance Goal By 2008 over 80% of HOPWA program clients will be in stable housing For competitive grantees, HUD expects at least half of beneficiaries will have stable housing during operating year

7. Stable Housing Outcomes Continuing with HOPWA assistance (TBRA or facility based assistance) Private housing Other subsidized housing Long term care/institution

8. Non-Stable Housing Outcomes Disconnected Jail/Prison Homeless (street/shelter)

9. Temporary Housing Preventing/avoiding homelessness Receiving STRMU and expected to need this assistance again in future to maintain housing Housing and services coordinated through Housing Services Plan

10. Access to Care and Services Outcomes Housing services plan Contact with case manager Contact with primary care provider Obtained health insurance/coverage Obtained employment

11. Client Eligibility Requirements Low income and living with HIV/AIDS People with documented HIV or AIDS Individuals or families with incomes at or below 80% of the Area Median Income

12. HIV Documentation Made by health professional competent to make determination Documentation from HIV tests conducted by physician, HIV counseling center, or community health center Case manager statement is not sufficient

13. Income eligibility requirements Income no greater than 80% of area median income Annual re-determination Household composition ? income of all family members over 18 counted Earned income disregard

14. People with Disabilities According to HUD?s definition of ?disabling conditions?, an HIV/AIDS diagnosis is considered a disabling condition Section 504 of the Rehabilitation Act of 1973 prohibits discrimination on basis of disability in HUD programs Reasonable accommodations are required to be made to allow people with disabilities to participate in HUD programs Cannot provide different or separate housing, aid or benefits to individuals or to any class of individuals with handicaps

15. Reasonable Accommodations Person with disabilities can receive support when housed with family member who owns the home Family income does not count toward assisted disabled person?s income Housing payments must be reasonable for type and nature of housing Must be determined by physician that living with family member is important to client?s overall health and well being ? case by case determination

16. How HOPWA Fits in HUD

17. Consolidated Planning Process Programs covered by Consolidated Plan CDBG Home ESG HOPWA Process 5 Year Consolidated Plan Annual Action Plan Establishes targets for annual HOPWA outcomes

18. HOPWA requirements in Annual Action Plan Annual goals specified for: Households to receive assistance through STRMU TBRA FBRA Method for selecting project sponsors Community based Faith based Changes such as instituting caps (STRMU) or limiting eligibility must be stated as part of Annual Action Plan

19. Citizen Participation Process Consolidated Plan requires consultation with: Organizations that provide housing and supportive services to those with special needs Organizations serving the chronically homeless Citizen Participation Local and regional institutions, developers, community organizations, faith based involved in plan development Comments included and ?adequately addressed? HOPWA Grantees and Project Sponsors strongly encouraged to participate in Consolidated Plan process

20. HOPWA Funds Allocation Formula Funds Competitive Grants Technical Assistance

21. HOPWA Formula Funds 90% of total HOPWA funding is available through ?formula grants? to states and eligible metropolitan statistical areas (EMSAs) FY 2007 formula funding is $256,162,000 25% of ?formula? is awarded as a bonus to EMSAs that have a higher than the average per capita incidence of AIDS reported in the prior year AIDS incidence data derived from CDC reports

22. HOPWA Formula Funds Eligible ?formula? areas must have: At least 1,500 cumulative cases of AIDS reported as of March 31st of the previous year Population of at least 500,000 in metropolitan areas HUD-Approved Consolidated Plan

23. Competitive Grants 10% of funds are available through ?competitive grants? to states, local governments, and non-profit organizations 2007 Competitive funding is $28.5 million Announcement / application for funding available through HUD?s annual Super NOFA process

24. Competitive Grants There are 2 types of competitive grants available to communities: ?Special Projects of National Significance? (SPNS) Housing and supportive services projects which are unique or innovative and likely to serve as effective models in addressing the housing and related needs of low-income persons living with HIV/AIDS ? grants to states, local government, or nonprofit ?Long-term Comprehensive Strategies? Funding to states and localities for areas that are not eligible for ?formula? grants (government only)

25. National Technical Assistance 1-2% of total competitive funding is set aside for the delivery of technical assistance, training and monitoring activities, including assistance in: Sound management of HUD Grants Performance measurement and data collection Establishing or operating housing subsidy programs and community residences Needs assessment and planning activities 2007 funding is $1.5 million

26. Grants Management Formula: 121 Grants including 81 cities, 1 county and 39 states Competitive: 85 Active grants Technical Assistance: 7 TA partners providing local training and other support on meeting program objectives Project sponsors: approximately 500 non-profits and a few housing agencies

27. Housing Outputs Households served 2004-2005 Program Year 21,846 rental assistance (50% expenditures) 39,068 short term assistance (24%) 6,098 housing facilities (20%) 400 new units (5%)

28. Housing Assistance 04-05, Clients Served by Housing Type

29. Housing Expenditures Annual Per Unit Costs (04-05 Program year): $3,750 Rental Assistance 811 Short-term payments 9,056 Operating costs in facilities 18,282 Development of new housing

30. Austin Formula Allocations

31. San Antonio Formula Allocations

32. State of Texas Formula Allocations

34. Definitions AIDS Disease of AIDS Any conditions resulting from the etiologic agent for AIDS HIV Infection

35. Definitions Eligible person ? a person with AIDS or a related disease who is a low income person and the person?s family Family ? 2 or more people who are related or important to care and well being and surviving members of an eligible person?s family

36. Definitions (Continued) Low Income ? below 80% of median Project Sponsor -- non-profit or local government agency that receives funds through contracts with a grantee Grantee ? state or local government receiving funds from HUD

37. HOPWA Regulations 574.3 Definitions 574.300 Eligible Activities 574.310c Religious organizations Can receive support on equal footing 574.310 General Standards Payments for health services not permitted if payment can reasonably be expected to be made by insurance or state compensation or health benefits program or on a pre-paid basis Health services only for PLWH/A Only permitted on case by case individualized basis See 1998 Notice on Use of Funds for Healthcare Costs

38. HOPWA Regulations 574-310 General Standards (Con?t) All housing assisted must meet housing quality standards (special requirements for STRMU) Minimum use periods: 10 years for any property involving acquisition, new construction or substantial rehabilitation 3 years for property with less than substantial rehab Recipients must pay rent (30% adjusted gross income or 10% of gross income)

39. HOPWA Regulations 574.310 General Standards (Con?t) Termination of assistance: Grace period of up to 1 year for surviving family members Violations of program requirements or conditions of occupancy Pursuant to formal process that affords due process

40. HOPWA Regulations 574.320 Additional Standards for Rental Assistance Maximum subsidy is lesser of Rent standard or Reasonable rent Rent is pro-rated in shared housing situations

41. HOPWA Regulations 574.330 Additional Standards for Short Term Supported Housing Short term facility can provide residence for not more than 60 days in a 6 month period STRMU is limited to 21 weeks in any 52 week period Short term facilities can house no more than 50 people

42. HOPWA Regulations 574.340 Additional Standards for Community Residences Multi-unit facility as a residential alternative to institutional care Adequate services must be provided Funding must be adequate Providers must be qualified Qualifies for new construction $?s Can be assisted through local TA

43. HOPWA Regulations 574.400 Special responsibilities 574.430 Fee Prohibition No fees other than rent charged to eligible persons 574.440 Confidentiality The name of any person receiving assistance shall be kept confidential by grantee and project sponsors

44. HOPWA Regulations 574.500 Grant Administration Environmental review for acquisition, new construction, rehabilitation or leasing of structures to provide housing Annual reports required Records maintained for 4 years Deobligation of funds if not expended in timely manner ? generally within 3 years

45. Confidentiality HOPWA regulations require that grantees and project sponsors ensure the confidentiality of both the name of any individual assisted by HOPWA and any other information regarding individuals receiving assistance. 24 CFR 574.440 Confidentiality. ?The grantee shall agree, and shall ensure that each project sponsor agrees, to ensure the confidentiality of the name of any individual assisted under this part and any other information regarding individuals receiving assistance.?

46. Confidentiality Procedures Information related to HIV only to be used for limited purpose of determining eligibility Only accessible to staff who determine eligibility or provide support Paper files maintained in locked cabinets; security software required for electronic files

47. Confidentiality Requirements Written procedures and training to maintain confidentiality Periodic monitoring of procedures and conduct appropriate training Failure to follow confidentiality procedures is default of grant responsibilities and could lead to loss of grant funds or other sanctions

48. Confidentiality Avoid inadvertent disclosures: Checks Caller ID?s Fax ID?s Housing quality inspections Publicity for project-based developments Other government reporting

49. Other Federal Requirements 574.600 Other Federal Requirements Non-discrimination and equal opportunity OMB Circulars A-87, A-102, A-110 and A-122 Conflict of Interest Displacement/relocation Lead based paint Flood insurance protection Audits

50. Lead Based Paint Housing built before 1978 Occupants include pregnant woman or a child <6 OBR units are exempt Applies to STRMU or TBRA Visual assessment must be done; deteriorated paint must be repaired using lead-safe work practices; repaired area must be tested and cleared ? HUD one hour on line course prerequisite to do visual assessment

51. Uses of Grant Funds Housing facilities Client assistance Housing subsidies Administration

52. Housing Facilities Facility based rental assistance Acquisition/rehabilitation New construction (special limitations) Operating costs Leasing

53. Housing Facilities Includes facilities that provide housing May or may not provide services onsite Facilities receiving capital support must provide housing to eligible PWA?s for at least 10 years Includes independent apartments or shared residences Rehabilitation must bring facility up to current ADA standards Includes lease of existing facility FBRA or operating expenses

54. Housing Facilities: Operating Costs Property Maintenance and Upkeep Security Measures Insurance Utility Costs for Facility Furnishings, Equipment, and Supplies Other Incidental Expenses

55. Housing Facilities: New Construction Special Limitations: Single Room Occupancy (SRO) Community Residences Including multi-unit family dwellings that provide a high-level, service-enriched environment

56. Housing Facilities: *Short-Term Supported Housing Facilities to provide temporary shelter May be hotel, motel, or shelter facility May provide residence to any individual for 60 days during any 6-month period The 60 days do not have to be consecutive HOPWA cannot provide hotel/motel vouchers *Not STRMU

57. Client Assistance: Supportive Services Provided onsite or for clients in housing programs Housing service plan Assessment for Case Management and Housing Needs Health Services ? limited to PLWA and no other source of payment Mental Health Care/Drug and Alcohol Abuse treatment and counseling Child Daycare/Adult Daycare Personal Assistance (intensive if required)

58. Client Assistance: Supportive Services, Cont. Nutritional Services Permanent Housing Placement Assistance Securing Other Mainstream Benefits Transportation Translation Services

59. Client Assistance: Housing Information Services Housing Information and Referral Housing Search and Assistance Housing Counseling Fair Housing Information Assistance in Completing Housing Applications Can support development of Housing Service Plans

60. Client Assistance: Housing Services Plans Determine housing needs and preferences Develop strategy to achieve or maintain housing stability Identify eligibility for other housing assistance Link to supportive services needed to maintain housing stability Eligibility for mainstream assistance Client sets goals for housing and independence Periodically revised and updated Housing case management or housing information services for funding under HOPWA

61. Client Assistance: Resource Identification Community based needs assessments Comprehensive HIV/AIDS housing plans Coordinate housing and supportive services HOPWA advisory boards Feasibility studies of housing projects Project start-up costs Financial and program accountability

62. Client Assistance: Permanent Housing Placement Supportive Service ? reported separately Help establish new residency where on-going occupancy is expected to continue Can cover: Costs associated with locating housing Housing referral (to decent, safe and sanitary housing) Tenant counseling/Understanding leases/mediation Secure utilities Placement costs Application fees/credit checks Reasonable security deposits (NTE 2 months rent) Deposits need to be tracked and returned to program

63. Client Assistance: Permanent Housing Placement Costs/activities not allowed Housing supplies Smoke alarms Standard furnishings Minor repairs Moving costs

64. Client Assistance: Resource Identification Unique tool for HOPWA Outreach and coordination with supportive housing projects and private landlords Housing information provided through brochures and web resources Staff time to locate and identify affordable housing vacancies

65. Housing Subsidies Tenant based rental assistance Short term rent, mortgage, and utility assistance (STRMU)

66. Housing Subsidies: Tenant Based Rental Assistance Section 8 ? like assistance program Subsidizes difference between ?rent standard? or reasonable rent (whichever is less) and tenant rental contribution Units must meet housing quality standards Rents plus utilities must not exceed rent standards (Fair Market Rents) Tenants may request interim rental adjustment based on increases or decreases in income

67. Housing Subsidies: Rent Reasonableness Subsidized rent is lesser of rent standard or reasonable rent Assisted unit rent should not be greater than rent charged for equivalent unit on private market Obtain and maintain in file documentation from brokers or advertisements on rents charged for comparable units

68. Housing Subsidies: TBRA Requirements Housing quality inspection Rent standard inclusive of utilities Cannot be combined with other HOPWA or HUD housing assistance Annual recertifications

69. Housing Subsidies: Short Term Rent Mortgage and Utility Assistance (STRMU) Prevents homelessness by keeping households in current dwelling Provides rent, mortgage, and/or utility support for no more than 21 weeks in a 52 week period Assistance may be subject to further limitation by grantees

70. Housing Subsidies: STRMU Cannot be used for first months rent or security deposit ? cannot assist homeless people Assistance must be paid to third party (i.e. mortgage, landlord, utility company) No cash payments Amount of assistance may vary depending on funds available, tenant needs, and program guidelines. (Caps may be applied) Annual reporting counts households assisted not payments

71. Housing Subsidies: STRMU and HOPWA Outcome Temporary solution Housing Services Plan key to achieving stability Maintain connections to key health and supportive services

72. Housing Subsidies: STRMU Tenancy Requirements Must already be housed to be eligible Must be named tenant or provide other evidence that they are legal resident Account in their name with utility or proof of responsibility to make payments (cancelled checks/money orders) Owner of mortgaged property Deed Title insurance policy Mortgage holder Default/late payment notice is not required

73. Housing Subsidies: STRMU Needs Based Program Needs must be documented through verifiable documents ? client should have no other means for payment and support will prevent homelessness If they are able, clients should pay portion of their housing costs under STRMU Portion of rent paid by tenant does not count against the 21 week STRMU benefit ceiling STRMU cannot be provided if assistance is also being received from any other HOPWA, federal, state or local housing subsidy program

74. Housing Subsidies: STRMU Documentation of Housing Need Inability to make monthly payment Record of monthly housing costs vs. income Limited available financial resources (savings, bank accounts, etc.) HIV/AIDS health conditions and impacts on resources

75. Housing Subsidies: STRMU Capped Payments Grantees may allow project sponsors to cap STRMU assistance Caps must reflect FMRs and/or rent reasonableness so that support is sufficient to prevent continuing housing crisis Caps must be applied in uniform, consistent and non-discriminatory manner If household receives max amount under cap, it will be considered a full 21 weeks of assistance

76. Housing Subsidies: STRMU Capped Payments and Con Plans Cap limit must be specified in Annual Action Plans Must be assessed by Grantee and monitored for consistency Assessment must be included in Annual Report to HUD

77. Housing Subsidies: Suitable Housing Units ? STRMU Required to assess whether unit is decent, safe and sanitary HQS not required initially if needed to prevent homelessness and unit is decent and safe Continued occupancy should require meeting of HQS Any deficiencies in unit should be addressed in housing service plan

78. Housing Subsidies: STRMU Calculating 21 Week Period Statute limits assistance to 21 weeks in any 52 week period Count calendar days of assistance with max being 147 (21 x 7) Can equate one month with 4 weeks of assistance yielding a maximum total of 5 months and 1 week of assistance Can precisely measure number of weeks in month (e.g., 4.3 weeks for 30 day month) Methodology must be consistent

79. Housing Subsidies: STRMU Calculating Annual Eligible Period All project sponsors must use same method to determine annual eligible period Standard annual period Grantee?s operating year Calendar year Separate period of eligibility for each client Year starts when client first receives STRMU assistance

80. Housing Subsidies: STRMU Rent and Utilities in 21 Weeks Housing costs are generally monthly; utility billing periods often include parts of 2 calendar months Provided that utilities and rent expenses are reasonably coincidental (at least 14 days of overlap), the monthly housing cost period can be used to determine the 21 week period

81. Housing Subsides: Expenses Not Covered by STRMU Personal items (grooming, clothing, home and personal furnishings, care for pets) Vehicle maintenance and repairs Financial assistance/consumer credit or entertainment activities Phone services (basic phone service and long distance ? in rural areas ? may be covered as supportive service when needed to access necessary services)

82. Housing Subsidies: STRMU Support for Mobile Homes, Trailers Can be assisted under STRMU in limited circumstances: Basis for assistance must be rent, mortgage or utility bill Mobile homes/trailers with wheels and capable of relocating are personal property and not eligible Must be attached to earth, connected to permanent utilities, & compliant with local guidelines for mobile homes

83. Administrative Fees Grantees no more than 3% for Administering grant amounts Allocating amounts to project sponsors. Sponsors no more than 7% Administrative costs associated with carrying out eligible activities Fees over entire term of grant No 7 - 7

84. Administration: Uses of Administration Funds General Management Oversight Coordination Evaluation Reporting

85. Administrative Expenses Include Staff for program coordination, management and evaluation Travel for official business Contracted services (legal, audit, accounting) Goods and services needed for admin Equipment rental and purchase Insurance and utilities

86. Ineligible Expenses for Administrative Costs Development of staff professional credentials General govt. expenses (e.g. building costs) Substitution for general funds. Tasks duplicated by grantee and project sponsor.

87. Administration: Other Funds for Planning, Reporting, Evaluation Resource Identification Technical Assistance Housing Information Services

88. Technical Assistance ? Local Assistance in establishing and operating a community residence (statutory) Training, orientation and capacity development Planning and pre-development activities Community outreach to neighbors of residence

89. Resources HUD Website: Updated STRMU Notice CPD 06-07 FAQ on STRMU Users Guides to New Annual Progress Report (APR) New CAPER IDIS Version 10 Logic Model

90. Purpose and Types of Monitoring What do program monitors look for? Tools Monitoring and Evaluation

91. Introduction Public Trust Responsibilities Federal and Grantee Partnership Consolidated Plan Technical Assistance

92. Monitoring Issues How are grantees selected for monitoring? How does HUD prepare for monitoring? What is expected to be seen on-site? ?Document, Document, Document? How are Findings and Concerns handled?

93. Overview Monitoring is a shared responsibility between HUD, grantees, sponsors. 3 types: HUD monitors grantees, grantees monitor sponsors; lead agencies monitor sub-grantees To make sure that program requirements are followed as intended by the law To strengthen administrative capabilities to better serve clients

94. Risk Analysis CPD Notice 04-12 Who poses the greatest risk? Financial; Physical; Management; Satisfaction; and Services.

95. Risk Analysis: 1. Financial a. Size of Grant b. Timeliness c. Timely Submission of OMB A133 Audits d. Financial Compliance e. Expenditure Provisions

96. RISK ANALYSIS: Continued

97. RISK ANALYSIS: Continued 4. SATISFACTION a. Citizen Complaints b. Grantee Responsiveness 5.SERVICES a. Meeting Program Objectives b.Carrying Out Program Activities c. Program Progress

98. Preparing for Monitoring The Consolidated Plan Goals Action Plan Activities Competitive application budget The CAPER or APR IDIS Reports Previous Monitoring Issues? Citizen Complaints?

99. Consolidated Plan 91.205. Housing and Homeless Needs Assessment. Must include persons with HIV/AIDS and their families. The Con Plan/Action Plan must estimate the number of type of families in need of housing including those with HIV/AIDS The size and characteristics of the population with HIV/AIDS and their families must be described

100. Consolidated Plan Cont?d 91.210. Housing Market Analysis The plan must describe the significant characteristics of the jurisdiction?s housing market, including the the supply, demand, and condition and cost of housing and the housing stock available to persons with HIV/AIDS.

101. Consolidated Plan Cont?d 91.215. Strategic Plan The plan must describe the general priorities for allocating investment geographically within the EMSA for the HOPWA program. The Con Plan must describe the priority housing and supportive service needs of persons with HIV/AIDS and their families

102. Action Plan (91.220) Includes a description of activities to be undertaken during the next year that will address the jurisdictions priority needs. The activities must describe the number and types of families that will benefit, the local objectives, and priority needs. Specify intended outcomes to be achieved Certification: HOPWA-funded housing activities are consistent with the strategic plan.

103. Client Eligibility Selection process ? waiting lists? Documentation of HIV/AIDS Status Documentation of 80% of median income, Section 8 definition, including third party verification, assets, unusual medical expenses etc. Confidentiality ? how is it maintained? At risk or homeless status ? how is it documented?

104. Housing HQS Inspections Correct rent calculations Income verified at least annually Policy Guide on Terminations Housing provided consistent with Con Plan Client Confidentiality Adequacy of Residential Supervision Adequacy of Supportive Services

105. Reporting CAPER, APR, IDIS, Logic Model, and LOCCS Are the number of participants served consistent with the Con Plan/Action Plan, the application and the numbers reported in the CAPER or APR? Are the Reports submitted in a timely manner and are they complete and accurate? How many people are on waiting lists? Are funds being spent in a timely manner? Are projected outcomes being achieved?

106. Reporting Annual set up of IDIS activities Close out of these activities, within 90 days of the end of the operating year on their Con Plan cycle. Consistency in IDIS data and CAPER summary information. Data included beneficiary information (race;ethnicity/age etc), expenditure data and housing outputs; outcome data reported Data is accurate, complete, avoids excessive use of ?other? or ?mixed? by showing specific costs by budget line item, and type of service

107. Grant Administration Client files must document grantees are conducting on-going assessments of the housing assistance and supportive services required by participants (574.500(b)(2)) Files should show adequate provision of services, e.g. by accessing mainstream programs, qualifying clients for benefits, ensuring payer of last resort Lease agreements between tenant/landlord or agency/landlord kept on file

108. Grant Administration Housing efforts should connect to long-term solutions, such as movement to permanent housing or independence, where possible. On STRMU, files must show this short-term assistance is limited, not more than 21 weeks in any 52 week period; or 60 days in any 6 month period in an short-term supported facility. Grantees must provide oversight on sponsors, e.g. on client documentation, rent determinations, rent reasonableness timeliness in use of funds, and reporting.

109. Property Standards Continued Use Requirements being followed? 10 years for new construction, substantial rehab or acquisition of a building Three years for properties involving non-substantial rehab.

110. Community Residences Is the required certification on file that the grantee has entered into a written agreement with providers for services? Is the funding appropriate for these services and providers capable? Are any physical improvements to the residences in compliance with applicable State and local housing codes?

111. Limits on Health Care HOPWA emphasizes housing Verify that HOPWA funds are not used for medical expenses individuals can receive under other programs Need to document the eligibility of these payments on an individual basis See the HUD Guidance dated January 21, 1998 in contracts on these limitations, requiring HUD?s pre-approvals

112. Financial Management OMB Circulars A-87/A-122 Part 84/85 Approved application & budget Vendor invoices, bank statements, time sheets, purchase orders Audit: Open Findings? Personal Property Controls (in excess of $5,000).

113. Financial Management Cont?d Grantee and sponsor employee time sheets should reflect actual times, not percentages. Time sheets should be signed and dated by the staff and then the supervisor. If employees split their time between programs (e.g. Ryan White) the time sheets should reflect this split.

114. Financial Management Cont?d Only actual incurred costs can be charged to HOPWA. For example. Don?t charge HOPWA for a counselor?s time spent with ineligible clients.

115. Financial Management Cont?d Draw funds down on a reimbursement basis from IDIS or LOCCS or Draw down funds only when they are needed to pay for incurred costs Rule of thumb: three days before paying a bill.

116. Other Federal Requirements Environmental: Part 58 applies Lead Based Paint: Applies if children under the age of seven will reside in the housing or facility. Relocation: URA applies Drug-Free Workplace: There should be a Drug-free Workplace Statement and it should be consistent with the program?s certification.

117. Findings and Concerns Monitoring letter A Finding results from non-compliance with regulatory or statutory requirements. A Concern results from the need for improvement in certain areas that could become a future finding. Findings and Concerns are entered into HUD?s Grants Management Process and controlled until they are satisfactorily addressed Range of sanctions

118. Resources available on CD HOPWA Program Environment review requirements Formula grant operating instructions Current and planned APR and CAPER IDIS HOPWA Handbook HOPWA Regs STRMU Notice Notice on Health Care Costs

119. CD Resources OMB Circulars A-87, Cost Principles for State and Local Gov?t A-110, Uniform Admin Requirements for grants and agreements ? for non profits A-122, Cost Principles for non profit organizations A-133 Audits of States, Local Gov?t and Non Profit Organizations


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